Building on Claude raises the same two questions as any foundation model: does using it make you a GPAI model provider under Article 53, and what are you the provider of in your own right? The answers are the same as for GPT or Mistral - the Act is model-agnostic - but the specifics of how teams use Claude change which parts bite.
Disclosure: Reglynn's own reports are generated by an AI system running on Anthropic's Claude, and reviewed before delivery. We classify ourselves as a Limited Risk system under Article 50 and publish our own assessment. This page describes the same analysis we applied to ourselves.
Calling the API keeps Article 53 with Anthropic
Anthropic is the GPAI model provider for Claude. The Article 53 obligations - technical documentation, copyright policy, the public training-data summary, cooperation with the AI Office - sit with them, not with you, when you call the API, prompt it, or fine-tune lightly within your domain.
What would move that line is substantial retraining that materially alters the model's general capability, or repurposing it into a new task domain. Prompting, retrieval augmentation and system-prompt engineering do not. The four factors that decide it.
You are still the provider of what you ship
Claude being Anthropic's doesn't change who is responsible for your product. Ship a feature under your own name and you are the provider of that AI system under Article 3(3) - classified by what it does, not by whose model runs it.
| What you build on Claude | Likely tier | What attaches |
|---|---|---|
| Customer-facing assistant or support bot | Limited | Article 50 disclosure - live now |
| Internal copilot, drafting, summarisation | Minimal | Article 4 literacy, little else |
| Document analysis where no person is evaluated | Minimal | Article 4; check the profiling line carefully |
| Anything scoring a person's access to work, credit, education or essential services | High-risk | Chapter III by Dec 2027 - see Annex III |
| Agentic workflows taking consequential actions about people | Assess carefully | Classified on effect, not autonomy; human oversight under Article 14 matters |
Two things specific to how Claude tends to get used
Long-context document analysis. A common Claude pattern is feeding it large documents - contracts, CVs, case files - and asking for analysis. The classification hinges on one question: is a natural person the subject of the evaluation? Summarising a contract is fine. Scoring the candidate whose CV you pasted is profiling, and profiling closes the Article 6(3) exemption absolutely.
Tool use and agents. Where a Claude-powered agent takes actions rather than producing text, the Act still classifies it by intended purpose and effect. What changes is Article 14: if the system does land in high-risk, human oversight has to be designed so a person can actually intervene - which is harder to retrofit onto an autonomous loop than onto a chat interface.
What you owe today
- Article 50 - one sentence at first contact if it converses with users. Live since 2 August 2026.
- Article 4 - recorded AI literacy for staff operating the system. What counts.
- Article 5 - no emotion inference in employment or education contexts.
- A dated written note of which systems you assessed and what you concluded - including the ones you decided were minimal risk, and why.
Anthropic publishes its own AI Act documentation for the model layer. That covers Claude; it does not cover the system you built on top, which is the part you're accountable for.
What did you actually build?
The free check classifies your system by what it does - which is what the Act cares about, not which model is underneath.
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Self-assessment, not legal advice. This page and the Reglynn report are a structured self-assessment based on the EU AI Act (Regulation 2024/1689, as amended by the June 2026 Omnibus). They indicate where you likely stand and what to verify with a qualified advisor. Reglynn is not a notified body and issues no certification.
How this was made. Reglynn reports are generated by an AI system built on Anthropic's Claude and reviewed before delivery. Reglynn is a Limited Risk AI system under Article 50; we disclose AI involvement wherever it occurs, including in our chat assistant. Our own self-assessment.